CFPB Assessing Its Integrated Mortgage Disclosure Rule

A new TILA RESPA Integrated Disclosure rule (TRID) caused concern a few years ago. The Consumer Financial Protection Bureau (CFPB) is now considering changes and accepting comments on its effectiveness. 

CFPB is requesting public comment as it assesses the TRID Integrated Disclosure Rule (the Truth in Lending Act and Real Estate Settlement Procedures Act). As part of the assessment, CFPB intends to address the rule’s effectiveness – how well it’s met the purposes and objectives of Title X of the Dodd-Frank Act. Has it achieved the desired goals? Are there any relevant factors about its effectiveness that should be considered?

Now that the TRID rule has been in effect for nearly five years, the Bureau is seeking feedback on how the rule is doing, with a specific focus on how the rule has affected consumers’:

  • understanding of their mortgage disclosures;
  • mortgage and settlement service shopping behaviors;
  • satisfaction with their mortgage disclosures, mortgage products, and settlement services; and,
  • ability to compare and choose among mortgages and settlement services.

The TRID Rule combined certain mortgage disclosures that consumers receive under the Truth in Lending Act (TILA) and the Real Estate Settlement Procedures Act (RESPA). The change now requires all creditors to use standardized forms for most transactions. Creditors must also provide loan estimates and closing disclosures within three business days.

The assessment is required under Section 1022(d) of the Dodd-Frank Act, which directs CFPB to assess significant rules or orders that were adopted under federal consumer financial law.

More information about submitting comments is posted online.

The comment period will open once the notice is published in the Federal Register; the deadline for submissions is January 21, 2020.

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